Privacy Policy

1 Who we are

1.1 We are AENO, ASBISc Enterprises PLC, Iapetou, 1, Agios Athanasios, 4101, Limassol, Cyprus.

1.2 This Privacy Policy sets out how we collect and use your personal information when you visit aeno.com (including our iPhone, Android apps) (hereinafter the Site) and the options available to you in connection with our use of your personal information (the Privacy Policy).
This Privacy Policy should be read alongside, and in addition to, our Site terms and conditions (accessible online at Terms and Conditions (Terms) and our Cookie Policy (accessible online at Cookie Policy). In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

2 The Privacy Policy

2.1 By providing access to the Site and Application (hereinafter the Site and Apps) we, acting reasonably and in good faith, believe that you:

• have all necessary rights to register on and use this Site and Apps;
• provide true information about yourself to the extent necessary for use of the Site Services and Apps;
• understand that by the posting your personal information you have manifestly made this information public, and this information may become available to the Administration;
• understand that some types of information transferred by you to other Site users cannot be deleted by you or us;
• are familiar with this Privacy Policy and accept it.

2.2 We do not check the user information received from you, except to the extent that such verification is necessary to fulfill our obligations to you.

2.3 This Privacy Policy shall be applicable to EU Citizens only. If you are not a EU Citizen, please refer to the Privacy Policy applicable in your jurisdiction.

3 Information we collect about you

3.1 In order to implement the agreement between you and us and provide you with access to the use of the Site functionality, we will improve the Site Services, develop and implement new Site and App Services, and enhance available Site and App functionality. To achieve these goals, and in accordance with applicable laws, we will collect, store, aggregate, organize, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.

3.2 We have set out in more detail the information we collect when you use our Site and App Services, why we collect and process it and the legal bases below.

3.3 Our legitimate interests include (1) maintaining and administrating the Site and App; (2) providing the Site Services to you; (3) improving the content of the Site; (4) processing of the data has been explicitly made public by you; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.

3.4 Your personal information may also be processed if required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims. We will not delete personal information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.5 You can withdraw your consent the collection of location data and your apps by amending your privacy settings on the mobile app/the privacy settings of your mobile device. You can withdraw your Start of active services, Startup after device is switched on Reading notifications in popups Network connection, viewing Sleep mode disabling, Wi-Fi Connection viewing, retrieving data from the Internet Vibration signal control Google Play Payment System, Wi-Fi Connection/Disconnection, Unlimited Internet Access Network setting changing, Play Install Referrer API in your phone settings. An option to unsubscribe will also be included in every email (as direct marketing) sent to you by us or our selected third-party partners if such direct marketing is realized in fact by us or our selected third-party partners with our permission.

3.6 Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on the Site. Once you provide this data it will be accessible by Administration and third-party partners, and it becomes difficult for us to remove this data.

3.7 Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Site and App, you may not be able to access or register with the Site and App.

3.8 If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we will provide you with details of that additional purpose before we begin processing.

4 Data sharing

4.1 Using VPN services, "Private Tab" mode, Tor Browser, etc. tools you can determine your confidentiality mode and the conditions of for accessing the information specified in paragraphs 2,3,4 and 7 in the table above. But in this case, we can not guarantee the quality of the services provided. We take technical and organizational measures to ensure that the appropriate Site and App tools are functional. Please note that when you post your personal information this may become available to internet users and be copied and/ or disseminated by such users. Once this data is transferred by you to other users you will not be able to delete this data.

4.2 We may share your data with Luxembourg-based AWS entity, Amazon Web Services EMEA SARL, ("AWS Europe") because some of our services are serviced there; for more details, see their data collection and storage policy at the following address: aws.amazon.com. Sometimes we may also need to share your data with a third party in order to provide our services to you or to administer the Site and App, for example if you choose to share your data across other social media platforms.

4.3 We may also share your data with our third-party contractors and application developers provided these third parties assume confidentiality obligations regarding your personal data collected by the Site and your use of the applications they offer. Data will only be shared with these developers with your consent. You can authorize developers to access your information via the Site and/or App.

4.4 The following services are used as an advertising management system: Google Analytics and Facebook Ads Systems is designed so that your information will not be shared directly with third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender or location, or to target communities according to type, e.g. cars or fashion. If you fall within one of the target groups, you will receive an advert or recommendation.

4.5 An advertiser or maker of recommendations may also choose to upload a list of emails, phone numbers and AENO Site and/or App identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.

4.6 Luxembourg-based AWS entity, Amazon Web Services EMEA SARL, ("AWS Europe") and other companies in the AMAZON, using their own ad services, may serve ads to you.

5 Privacy Settings

5.1 The Site contains links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.

5.2 We are not responsible for the actions of third parties that, as a result of your use of the Internet or the Site Services, gain access to your information in accordance with the Internet privacy level you have chosen (4.1).

5.3 We are not responsible for the consequences of using information that, due to the nature of the Site in the Application, may be available to any Internet user, if you grant access rights to your personal account Profile and/or the Application. We ask you to responsibly approach the integrity of information about the username and password and remind you that it is forbidden to share such information in accordance with the rules described in the user agreement.

6 International Transfers

6.1 We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including Ukraine and Republic of Belarus.

6.2 The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standartd Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

7 Retention Periods

7.1 We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

7.2 You can delete your personal data by deleting data from your personal page; alternatively, you can delete your page using the "Delete my profile" function available in the "My settings" section. You have the right to restore your personal profile within 90 days after deleting your personal page.

7.3 We may delete your Profile or the information you post on the Application if we have grounds provided for by applicable law or in accordance with the Terms.

8 Your Rights

8.1 Under certain circumstances, you have the following rights in relation to your personal information:

1. The right to access your personal information.
2. The right to correct your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
3. The right to restrict the use of your personal information.
4. The right to request that your personal information is erased.
5. The right to object to processing of your personal information.
6. The right to data portability (in certain specific circumstances).
7. The right not to be subject to an automated decision.
8. The right to lodge a complaint with a relevant supervisory authority.

8.2 You also have a right to independently remove your Profile, information on your Profile and make changes and corrections to your personal Profile on the Site and App, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you via the Site.

8.3 If you would like to exercise these rights, please send your request to us in our Support Service Support, or in writing to AENO, ASBISc Enterprises PLC, Iapetou, 1, Agios Athanasios, 4101, Limassol, Cyprus. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.

9 Security Measures

9.1 We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

9.2 Access to the Site is carried out your login (e-mail address) and password. You are responsible for maintaining the confidentiality of this information.You must not share your credentials with third parties and we encourage you to take steps to keep this information confidential.

9.3 If you forget your login details and we have your mobile phone number, you can ask us to send you an email containing a recovery code using a special tool available here: aeno.com.

9.4 To reduce the possibility of unauthorized access by third parties, if you log into your account from an unusual server (in particular, from a server located in another country), we will block access to your personal page. You will then receive a message asking you to provide certain digits indicated in a message sent to your mobile phone number. After three unsuccessful attempts to enter these digits, we will block access from that server for 4 hours.

9.5 You can access information about the time and device from which your account was accessed using the Show activity history link in the My Settings.

10 Changes to this Policy

10.1 We may change and/or update this Privacy Policy from time to time. If this Privacy Policy changes in any way, we will post an updated version on this page. We will keep previous versions of this Privacy Policy in our records. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such. At the moment, we collect only the data necessary for the correct operation of the Site and the Application in accordance with Articles 15-18 of the Regulation (GDPR). Your right to delete personal information under Article 5 of the GDPR has been exercised. The system for transferring data to other countries within the Holdings was developed and configured on the basis of Article 45 of the Regulation (GDPR). We also use a payment system with pre-bank payment processing in which we are guided by the Payment Policy and Cookie Policy. Within our company, a Personal Data Protection Policy has been developed and implemented in accordance with article 24 of the regulation. Inventory of Processing Activities in accordance with Article 30 of the Regulation and Security incident response policy, as well as a system has been developed and introduced to notify personal data subjects and the supervisory authority of cases of hacking and leakage in accordance with Article 33 of the regulation (GDPR).

11 Contact Us

11.1 If you have any questions, please send your inquiries to us, in writing to: AENO, ASBISc Enterprises PLC, Iapetou, 1, Agios Athanasios, 4101, Limassol, Cyprus, or to Support. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.

11.2 All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

11.3 The e-mail address of our DPO is support@aeno.com